FDIC Federal Register Citations

Subject: customer identification programs for banks

To Whom it may concern:

Under the proposed regulation regarding Customer Identification Programs at 12 C.F.R. 103.121(b)(3)(i)(B) it appears that banks will be required to maintain copies of documents used to verify identities (i.e., government issued identification, such as passports, driver's licenses, etc.).
Wisconsin state law prohibits copying of driver's licenses. Also, federal regulators have been critical (under the auspices of Fair Lending Regulations (Regulation B)) for maintaining copies of these types of
documents in loan files. Will the final rule contain a pre-emption clause? And, how do banks reconcile fair lending concerns with CIP programs?

Regards,

Stephen Mills